This Shopper Privacy Policy (this "Policy") explains how Tokko Labs, Inc. (d/b/a Clero, "Clero," "we," "us," or "our"), a Delaware corporation registered to do business in the State of Washington, collects, uses, shares, and protects personal information about people who visit or buy from the online stores that Clero operates on clero.com for brands ("Storefronts"). Clero builds and operates each Storefront and sells the brand's products on the brand's behalf; purchases are governed by our Shopper Terms of Sale.
1. Scope of This Policy
This Policy covers personal information we process about shoppers: people who visit a Storefront, open a creator's link to one, or place an order, including guest shoppers who buy without an account. Clero is the controller of this information. The brand whose products a Storefront sells (the "Brand") does not receive your name, delivery address, email address, or phone number, except as described in Section 6. If you also use Clero as a Brand, Creator, or Maker, the Brand, Creator, or Maker Privacy Policy covers that use.
2. Controller and Contact
- Controller: Tokko Labs, Inc. (d/b/a Clero), 300 Deschutes Way SW, STE 208, MC-CSC1, Tumwater, WA 98501, United States.
- Privacy contact: support@clero.com (privacy questions and requests); admin@clero.com (legal notices and escalations).
3. Personal Information We Collect
- Checkout information — your email address, your name and delivery address, and a phone number, which we store in encrypted form.
- Order information — the products and options you buy, prices, shipping charges, tax, totals, the order's status and dates, refunds, and the private link to your order, which contains a secret code.
- Payment information — Stripe collects your card or other payment details through its payment form; we do not receive or store full card numbers. We receive from Stripe the status of your payment and of any refund and, if you dispute a charge, the dispute's status, amount, and the reason your card issuer gives.
- Shipping and tracking information — the carrier and tracking number of your order, and its delivery status and tracking events, which we obtain from our shipment-tracking provider.
- Creator link information — when you open a creator's link to a Storefront, the link's code; if you then place an order, we record with your order the creator whose link brought you (Section 7).
- Support communications — the messages you send us and our replies.
- Technical information — your IP address, browser and device type, and the pages you request, which our servers and security systems log.
4. Sources of Personal Information
We collect personal information from you at checkout and when you contact us; from your browser (Section 7); from Stripe; and from carriers and our shipment-tracking provider.
5. How We Use Personal Information
We use personal information to (a) process, ship, and deliver your order, and show it to you through your order link; (b) send you your order link and messages about your order, and respond to you; (c) contact you about a problem with delivering your order, which is the only purpose for which we and the carrier use your phone number; (d) calculate sales tax from your delivery address; (e) handle returns, refunds, and payment disputes; (f) credit an order to the creator whose link brought you, and report credited sales to the Brand without your personal details; (g) prevent fraud and misuse and keep Storefronts secure; (h) keep the records the law requires for tax, accounting, and other purposes, and comply with legal obligations; and (i) understand and improve Storefronts using aggregated or de-identified information.
We do not currently send marketing messages to shoppers. If we begin to, we will update this Policy first and give you a way to opt out of them.
Where the GDPR or a similar law applies, we process personal information to perform our contract with you (to take, ship, and support your order), to comply with legal obligations (such as tax and accounting records), and for our legitimate interests (preventing fraud, securing Storefronts, crediting creators and reporting sales to Brands, and improving Storefronts).
6. How We Share Personal Information
- With Stripe — Stripe processes your payment, refunds, and payment disputes, may use information about your payment and device to prevent fraud, and may also be used to calculate sales tax from your delivery address, under its own privacy policy.
- With carriers — the carrier delivering your order receives your name and delivery address and, where the carrier needs it, your phone number, which it may use only for problems with delivering your order.
- With our shipment-tracking provider (AfterShip) — it receives the carrier and tracking number of your order so that we can show you its delivery status.
- With our other service providers — cloud hosting, storage, and email delivery (Amazon Web Services) and customer-support tooling, under contracts that limit their processing to our instructions.
- With the Brand — the Brand sees its Storefront's orders: the products, amounts, status, refunds, and payment disputes, the carrier and tracking number, and the creator credited. It does not see your name, delivery address, email address, or phone number. If you report a reaction to a product, we pass information about it to the Brand, which is responsible for the product's safety, but we give the Brand your name or contact details only if you agree or the law requires it.
- With creators — creators do not receive personal information about you; the Brand sees the sales each creator's links brought.
- With professional advisors — lawyers, accountants, auditors, and insurers under confidentiality obligations.
- With authorities — when required by law, subpoena, or court order, or to protect rights, safety, or the integrity of Storefronts.
- In corporate transactions — in connection with a merger, acquisition, financing, reorganization, or sale of assets, subject to continued protection of personal information.
We do not sell personal information, and we do not share personal information for cross-context behavioral advertising, as those terms are defined under the CCPA/CPRA.
7. Creator Links, Cookies, and Browser Storage
Storefronts keep a small amount of information in your browser so that they work: your cart and, when you arrive through a creator's link, that link's code, for a limited time. During checkout, your browser also creates an identifier for the checkout attempt, so that trying again does not create a second order. If you place an order in the same Brand's Storefront while a creator's link code is still stored, the code is sent with your order and the order is credited to that creator. You can remove this information by clearing your browser's storage for clero.com; your cart and any creator credit are then lost. Stripe's payment form may set Stripe's own cookies and collect information about your device to process payments and prevent fraud, under Stripe's privacy policy. We do not currently use analytics or advertising cookies on Storefront pages; if we begin to, we will update this Policy first.
8. Data Retention
| Category | Typical retention |
|---|---|
| Orders, including your checkout information (email address, name, delivery address, and phone number), payment, refund, and dispute records, the carrier and tracking number, and the creator credited | 7 years after the order (tax, accounting, and dispute records) |
| Support communications | 24 months |
| Technical and security logs | 13 months |
| Information kept in your browser | Until it expires or you clear it |
We retain data longer where required by law, legal hold, or an ongoing dispute, and we may retain de-identified or aggregated data without time limit.
9. Your Privacy Rights
Depending on where you live, you may have rights to know about, access, correct, delete, or receive a copy of your personal information, and to appeal our decision on a request. To make a request, email support@clero.com from the email address you used at checkout and include your order number. We will verify your request and respond within the time the law requires. We may keep information that the law requires us to keep, such as tax and transaction records (Section 8). If we refuse your request, you may appeal by replying to our decision or by emailing admin@clero.com. An authorized agent may make a verifiable request on your behalf, and we will not discriminate against you for exercising your rights.
10. California Privacy Notice (CCPA/CPRA)
For California residents: we collect identifiers (such as your name, email address, phone number, delivery address, and IP address), commercial information (your orders), and internet activity information (such as the creator link that brought you and the pages you request), from the sources in Section 4, for the purposes in Section 5, and we disclose them for business purposes to the recipients in Section 6. We do not sell personal information or share it for cross-context behavioral advertising, and we do not use or disclose sensitive personal information for purposes that require offering a right to limit. California residents may exercise the rights to know, access, correct, and delete, and the right to non-discrimination, as described in Section 9.
11. Other US State Privacy Notices
Residents of other US states with comprehensive privacy laws (including Washington, Colorado, Connecticut, Virginia, Texas, and Oregon) may have similar rights, which they can exercise as described in Section 9. We do not sell shoppers' personal information or process it for targeted advertising.
12. Children's Privacy
Storefronts are not directed to children under thirteen (13), and you must be at least eighteen (18), or the age of majority where you live, to place an order. We do not knowingly collect personal information from children under 13; if we learn that we have, we will delete it promptly. Contact support@clero.com about any suspected child data.
13. Security
We protect personal information with administrative, technical, and physical safeguards, including encryption in transit and at rest, an additional layer of encryption for your phone number, and access controls that limit your checkout information to Clero staff who handle orders. The link to your order contains a secret code: anyone who has the link can see your order, so keep it private. No security program is perfect.
14. International Data Transfers
We are based in the United States, and our own systems store personal information in the United States. Some of our service providers process personal information in other countries, under contractual restrictions.
15. Changes to This Policy
We may update this Policy from time to time. The updated Policy shows a new version and effective date. This Policy is drafted in English; translations are provided for convenience only, and the English version controls if there is any conflict.
16. Contact
- Privacy questions and requests: support@clero.com
- Legal notices and escalations: admin@clero.com
- Address: Tokko Labs, Inc. (d/b/a Clero), 300 Deschutes Way SW, STE 208, MC-CSC1, Tumwater, WA 98501, United States